National Trends in Organ Acquisition Costs

Brigitte SullivanAdministrative Director

The Johns Hopkins Comprehensive Transplant Center

Today

• Brief History of Organ Acquisition

• Audit Experience

• Available Benchmarking Data

Unique Reimbursement for Transplantation

• Medicare reimburses hospitals for organ transplants by paying a DRG for the hospitalization

• Medicare also pays hospitals for transplant services based on the Organ Acquisition Costs reported on the hospital’s Medicare Cost Report

• Transplant is one of the few areas within a Hospital that is reimbursed on costs through the MCR

• Medicare is a major revenue stream for transplant hospitals and programs ($4.7M annual)

Medicare Organ Acquisition• Organ acquisition costs include:

– OPO fees– Support costs: transplant coordinators, transplant

database, financial counselors– Pre-transplant evaluation services– Deceased donor and living donor hospital expenses– Share of hospital overhead

• Cost reimbursed:– Medicare usable organs/total usable organs x total

organ acquisition costs

OAC Timeline• 1974 – Medicare Reimbursement for OAC based on reasonable

cost basis. CTC establishes 1 SAC for DD and 1 for LD, after the close of the FY, the charges are aligned with actual costs, and any necessary adjustments are made

• 1983 – HCFA establishes Medicare PPS, plans to include OAC in DRG; however decides to leave cost reimbursement because of the “unique characteristics of organ procurement activities and the desirability of maintaining an adequate supply of kidneys.”

• 1987 OIG Report “Organ Acquisition Costs: An Overview”– Estimated $52.3M spent on kidney SAC in 1985 ($20-30K per

transplant)– Recommended Demonstration Project & that OAC incorporated

into DRG for kidney transplant– FI’s conduct priority audits of OAC

OAC Timeline• 1991 OIG Report “Addressing Increased Organ

Acquisition Costs” - HCFA felt not enough $ to invest HCFA resources in recommendations

• 2002 – CA whistleblower case - $6.2M Medicare refund and 2004 OIG push to audit OAC

• 2006 – OIG Publishes Results of Audits done in 2005– Recommended that “CMS consider the results of our

11 audits in prioritizing areas to be evaluated in annual audits by the fiscal intermediaries.”

OIG Audit Results  Years

Audited Claimed Costs Medicare Reimbursement

Estimated Medicare

Overpayment

Total 21 $203,281,448 $105,094,038 $28,430,118 Average Per Hospital 1.9 $18,480,132 $9,554,003 $2,584,556

Cost Category Unallowable UnsupportedMedicare Share of

Unallowable & Unsupported

Salaries $ 1,177,528 $ 24,506,226 $ 14,818,705 Medical director fees $ 1,512,210 $ 1,803,027 $ 2,084,638

Laboratory costs $ 1,589,176 $ - $ 1,273,992

Floor space $ 2,050,939 $ 5,618,406 $ 5,027,405 Other costs $ 4,878,419 $ 3,669,597 $ 5,225,378 Total $ 11,208,272 $ 35,597,256 $ 28,430,118

$124M not audited: Medicare eligibility of beneficiaries, Inpatient days claimed, Indirect cost pools on B Worksheets

Unallowable/Unsupported Costs• Lacked effort reporting for salaries & med

director fees pre/post

• Did not use reasonable compensation equivalent limits on medical directors’ compensation

• Lacked a method to accumulate allocation statistics on floor space

Common Error: Did Not Include All Direct Costs

Total Costs in OAC

Total Transplanted

OrgansMedicare

TransplantsMedicare

RatioMedicare Payment

Does not Include Non-Medicare Patient Costs $ 1,000,000 50 25 50% $ 500,000

Does Include non-Medicare Patient Costs

$ 2,500,000 50 25 50% $ 1,250,000

OIG Audits

• Officials at the Hospitals either asserted that they lacked awareness and understanding of Medicare requirements for claiming OAC, or that they had inadvertently claimed costs that were not allowable

• OIG audits are instructive for both risk areas and potential cost recoveries

What Do Organ Acquisition Costs Look Like?

Milliman & Robertson

*“Procurement…includes donated organ recovery services, which may include retrieval, preservation, transportation, and other acquisition costs…we based procurement charge estimates on our judgment and…data from Washington hospitals, trended to [the current year] and normalized to a national average basis using Milliman area relativity research.” – M&R 2005 report

Organ Type

2011 Estimated U.S. Billed Charges Per Transplant for Procurement (in 1,000's) % Increase 2002-

20112002 2005 2008 2011

Heart $ 57 $ 74 $ 94 $ 80 $ 23 41%Kidney $ 46 $ 51 $ 68 $ 67 $ 22 47%Liver $ 54 $ 57 $ 74 $ 71 $ 17 31%Lung - Single

$ 58 $ 42 $ 54 $ 73 $ 15 26%

Lung - Double $ 83 $ 97 $ 90 $ 24 40%Pancreas $ 44 $ 67 $ 68 $ 65 $ 21 48%

Payor Practices

• Global/case rates• $25K to $50K OA Caps• Payment of Invoice from OPO• No coverage

Organ Procurement Organization Kidney Standard Acquisition Charges

Source: Medicare Fiscal Intermediaries for OPOs - Trailblazer <2009, Cahaba >2009

HCRIS Data• Hospital Cost Report Information

System• All Medicare Cost Reports in the U.S.• Publicly Available

Definitions• CTC = Certified Transplant Center

• Hospital = The institution that performs transplants. One Hospital can have multiple CTCs

• Each Cost Report is for one Hospital. There are multiple CTCs defined on a given Report, through completion of the D-6 Worksheets (one D-6=one CTC)

Hospitals with CTC(s) in Dataset

2001 2002 2003 2004 2005 2006 2007 2008 2009 20100

50

100

150

200

250

Status of Cost Reports as of September 2012

Amended As Submitted ReopenedSettled Settled With Audit

CTCs in Dataset

2009 Detailed Analysis

UNOS HCRIS % Data in Data

Unique Hospitals performingat least 1 Transplant in 2009 253 234 92%

Total Organs Transplanted in 2009 28,459 28,808 101%

ORGAN CTCs Total

Usable Organs

% Medicare Usable Organs

Total Transplanted

Organs

% Living Donor

Transplants

Heart 107 2,655 41% 2,127  Intestine 9 166 20% 150  Kidney 226 22,101 68% 17,245 36%Liver 113 7,512 37% 6,055 4%Lung 53 2,457 42% 2,067  Pancreas 120 1,654 63% 1,164 Total 628 36,545 57% 28,808 22%

Reporting VariabilityTotal Costs Per Usable Organ

Organ CTCs2009 Total Cost Per Usable Organ

Average Standard Deviation Minimum Maximum

Heart 107 $ 79,328 $ 38,382 $ 23,249 $ 321,118

Intestine 9 $ 96,434 $ 67,894 $ 45,528 $ 267,297

Kidney 226 $ 50,694 $ 27,584 $ 10,882 $ 249,371

Liver 113 $ 63,273 $ 33,563 $ 20,873 $ 285,002

Lung 53 $ 65,328 $ 32,962 $ 21,165 $ 177,878

Pancreas 120 $ 44,282 $ 41,667 $ 992 $ 423,594

Total 628 $ 58,539 $ 40,564 $ 992 $ 423,594

3690 (Cont.) FORM CMS-2552-96 09-01COMP UTATION OF ORGAN ACQUISITION P ROVIDER NO.: P ERIOD: WORKSHEET D-6,COSTS AND CHARGES _____________ FROM ________ P ARTS III & IV

OP O NO.: TO __________Check [ ] HEART [ ] LIVER [ ] P ANCREAS [ ] OTHER (specify)Applicable Box [ ] KIDNEY [ ] LUNG [ ] INTESTINE

PART III - SUMMARY OF COSTS AND CHARGES

Part A Part B Part A Part B 1 2 3 4

48 Routine and Ancillary from Part I 300,651,040$ X 48

49 Interns and Residents (inpatient) X 49

50 Interns and Residents (outpatient) X 50

51 Direct Organ Acquisition (see instructions) 1,846,727,313$ X 51

52 Cost of Services of Teaching Physicians (Wkst. D-9) X 52

53 Total (sum of lines 48 thru 52) 2,147,417,252$ 53

54 Total Usable Organs (see instructions) 36,545 54

55 Medicare Usable Organs (see instructions) 21,004 55

56 Ratio of Medicare Usable Organs to Total 56

Usable Organs (line 55 ÷ line 54)57 Medicare Cost/Charges (see instructions) X 57

58 Revenue for Organs Sold 467,053,241$ X 58

59 Subtotal (line 57 minus line 58) X 59

60 Organs Furnished Part B X X 60

61 Net Organ Acquisition Cost and Charges 1,099,332,078$ X X 61

Cost Charges

57%

FY2009 Cost Report D-6, Part III Worksheet for All Organ Types

FY2009 Cost Report D-6, Part IV Worksheet for All Organ Types

PART IV - STATISTICS

Living Related Cadaveric Revenue1 2 3

62 Organs Excised in Provider (1) 6,208 8,018 -$ 62

63 Organs Purchased from Other Transplant Hospitals (2) 67 1,486 -$ 63

64 Organs Purchased from Non-Transplant Hospitals - 417 -$ 64

65 Organs Purchased from OPOs 359 21,115 -$ 65

66 Total (sum of lines 62 thru 65) 6,634 31,036 -$ 66

67 Organs Transplanted 6,401 22,414 467,053,241$ 67

68 Organs Sold to Other Hospitals 45 289 658,502$ 68

69 Organs Sold to OPOs 128 6,543 32,592,678$ 69

70 Organs Sold to Transplant Hospitals 22 957 7,465,139$ 70

71 Organs Sold to Military or VA Hospitals - - 1,116,000$ 71

72 Organs Sold Outside the U.S. - - -$ 72

73 Organs Sent Outside the U.S. (no revenue received) - - -$ 73

74 Organs Used for Research - 174 -$ 74

75 Unusable/Discarded Organs 1 663 -$ 75

76 Total (sum of lines 67 thru 75 should equal line 66) 6,597 31,077 -$ 76

(1) Organs procured outside your center by a procurement team from your center are not to be included in the count.(2) Organs procured outside your center by a procurement team are included in the count.

Line 51 “Direct Organ Acquisition”

= Direct Costs from Worksheet A+

Indirect Costs from Worksheet B

Direct CostsDirect costs that are directly related to organ acquisition and are accumulated in the organ

acquisition cost centers on Worksheet ARev. 1 36-51310-96 FORM CMS-2552-96 3690 (Cont.)RECLASSIFICATION AND ADJUSTMENT OF TRIAL BALANCE OF EXPENSES PROVIDER NO.: PERIOD: WORKSHEET A

FROM _______________________ TO ___________

RECLASSIFIEDNET EXPENSES

COST CENTER DESCRIPTIONS TOTALRECLAS

SIFI-TRIAL

BALANCEFOR ALLOCATION

(omit cents)SALARI

ESOTHER (col. 1 + col.

2)CATION

S(col. 3 ± col.

4)ADJUSTM

ENTS (col. 5 ± col. 6)1 2 3 4 5 6 7

70 7000Intern-Resident Service (not appvd. tchng. prgm.) X X X 7071 7100Home Health Agency X X X 71

SPECIAL PURPOSE COST CENTERS 82 8200Lung Acquisition X X X 8283 8300Kidney Acquisition X X X 8384 8400Liver Acquisition X X X 8485 8500Heart Acquisition X X X 8586 Other Organ Acquisition (specify) X X X 8688 8800Interest Expense X X - 0 - 88

Guidance from Medicare: Reporting Salary• The costs associated with preservation

technicians, transplant coordinators, and administrators, etc. must be allocated among the types of organs procured

• The provider must establish a unit cost per organ by dividing the indirect cost by the total number of organs retrieved

• This unit cost is multiplied by each organ obtained

FY09 Salary Reported on Worksheet A

% Hospitals Reporting $0 20%All Organs Cost Per Usable Organ $ 9,164

% Total Cost Per Usable Organ 15.4%Heart Cost Per Organ $ 20,634 Kidney Cost Per Organ $ 8,536 Liver Cost Per Organ $ 8,123 Lung Cost Per Organ $ 5,593

Guidance From Medicare: Reporting Other Direct Costs• Fees for physician services (preadmission for transplant

donor and recipient tissue-typing and all tissue-typing services performed on cadaveric donors);

• Cost for [organs] acquired from other providers or [organ] procurement organizations;

• Transportation costs of [organs]; • [Organ] recipient registration fees; • Surgeons' fees for excising cadaveric donor [organs];

and • Tissue-typing services furnished by independent

laboratories

Other Direct Organ Acquisition Costs from Worksheet A

% Hospitals Reporting $0 8%

Overall Cost Per Usable Organ $ 33,129 % Total Cost Per Usable Organ 55.7%Heart Cost Per Organ $ 44,996 Kidney Cost Per Organ $ 30,713 Liver Cost Per Organ $ 36,336 Lung Cost Per Organ $ 32,229

2009 OPO Kidney SAC = $27,543

Indirect Costs• Transplant center overhead costs that are

accumulated in general service cost centers and allocated through the cost report “step-down” process on Worksheet B

• Include staff fringe benefits based on salaries, space costs (depreciation, plant operations, utilities, etc) based on SQF, equipment depreciation, social services, general administration based on accumulated cost, data processing, and other costs as appropriate and consistent with the overall allocation process.

Worksheet BRev. 308-97 FORM CMS-2552-96COST ALLOCATION - STATISTICAL BASIS P ERIOD: WORKSHEET B-1 P ROVIDER NO: P ERIOD:

FROM ____________ FROM ____________TO _______________ _______________ TO _______________

ADMINIS- MAIN- LAUNDRY

MAIN- NURSING CENTRAL MEDICAL

TRATIVE &

TENANCE &

OPERATION

& LINEN HOUSE-TENANCE

OFADMINIS-

SERVICES &

RECORDS &

GENERAL REPAIRS OF PLANT SERVICE KEEPING DIETARY CAFETERIA

PERSONNEL

TRATION SUPPLY PHARMACY

LIBRARY

COST CENTER DESCRIPTIONS (ACCUM. (SQUARE (SQUARE(POUND

S OF(HOURS

OF(MEALS (MEALS (NUMBER (DIRECT (COSTED (COSTED (TIME

COST) FEET) FEET)LAUNDR

Y)SERVICE) SERVED) SERVED) HOUSED)

NURS. HRS)

REQUIS.) REQUIS.) SPENT)

6 7 8 9 10 11 12 13 14 15 16 1771 Home Health Agency

SP ECIAL P URP OSE COST CENTERS 82 Lung Acquisition83 Kidney Acquisition84 Liver Acquisition85 Heart Acquisition86 Other Organ Acquisition (specify)

92 Ambulatory Surgical Center (Distinct P art)93 Hospice94 Other Special P urpose (specify)95 SUBTOTALS (sum of lines 1-94)

NONREIMBURSABLE COST CENTERS 96 Gift, Flower, Coffee Shop, & Canteen97 Research98 P hysicians' P rivate Offices99 Nonpaid Workers

100 Other Nonreimbursable (specify)101 Cross foot adjustments 102 Negative cost centers 103 Cost to be allocated (per Wkst. B, P art I) X X X X X X X X X X X X104 Unit cost multiplier (Wkst. B, P art I) X X X X X X X X X X X X105 Cost to be allocated (per Wkst. B, P art II)106 Unit cost multiplier (Wkst. B, P art II)107 Cost to be allocated (per Wkst. B, P art III)108 Unit cost multiplier (Wkst. B, P art III)

Allocation of Worksheet B Costs

Cost Category% Hospitals Reporting

$0

Reported Cost Per Usable

Organ

% Total Cost Per Usable Organ

Administrative & General 0% $ 7,140 12.0%Cafeteria 15% $ 129 0.2%Central Services & Supply 58% $ 68 0.1%Dietary 93% $ 96 0.2%Employee Benefits 12% $ 1,219 2.0%Interns & Residents Program Costs 90% $ 105 0.2%Interns & Residents Salary & Fringes 92% $ 92 0.2%Laundry & Linen Service 86% $ 9 0.0%Maintenance & Repairs 55% $ 260 0.4%Maintenance of Personnel 99% $ 2 0.0%Medical Records & Library 41% $ 213 0.4%Nursing Administration 49% $ 270 0.5%Nursing School 99% $ 0 0.0%

Allocation of Worksheet B Costs

Cost Category

% Hospitals Reporting

$0

Reported Cost Per

Usable Organ

% Total Cost Per Usable Organ

Operation of Plant 36% $ 480 0.8%Other General Service 83% $ 517 0.9%Paramedical Education 89% $ 12 0.0%Pharmacy 77% $ 28 0.0%Social Service 73% $ 385 0.6%Old Capital Related Costs - Bldgs & Fixtures 91% $ 27 0.0%Old Capital Related Costs - Movable Equipment 96% $ 3 0.0%New Capital Related Costs - Bldgs & Fixtures 27% $ 361 0.6%New Capital Related Costs - Movable Equipment 42% $ 197 0.3%

Organ Acquisition DayAn organ acquisition day is an inpatient

day of care rendered to:• an organ donor patient who is hospitalized

for the surgical removal of an organ for transplant

• a cadaver in the inpatient routine service area for the purpose of surgical removal of organ(s) for transplant

FY09 Inpatient and Routine Ancillary Costs Per Day and Per Organ

  

Routine & Ancillary Days Reported

>0 0 Total

Hospitals 218 16 234 Inpatient OA Days Reported 23,431 - 23,431 Deceased Donor Organs Excised at Hospital 7,964 54 8,018 Living Donor Organs Excised at Hospital 6,069 139 6,208 % Living Donors 43% 72% 44%Days Per Donor Reported 1.67 N/A 1.65 Per Diem Cost $12,761 N/A $12,831 Reported Routine & Ancillary Costs Per Organ Excised $21,307 $8,583 $21,134 Reported Revenue Per Organ Excised $2,964 $1,268 $2,941

Medicare Usable Organs(from Medicare Provider Reimbursement Manual)

• Equals total usable organs minus organs sent to military hospitals, to veterans’ hospitals, outside the United States, and organs transplanted into non-Medicare beneficiaries.

• Include organs that had partial payments by a primary insurance payer in addition to Medicare.

•Do not include organs that were totally paid by primary insurance other than Medicare, as they are non-Medicare.

•Do not include organs procured from a non-certified OPO.

FY2009 Cost Report D-6, Part IV Worksheet for All Organ Types

PART IV - STATISTICS

Living Related Cadaveric Revenue1 2 3

62 Organs Excised in Provider (1) 6,208 8,018 -$ 62

63 Organs Purchased from Other Transplant Hospitals (2) 67 1,486 -$ 63

64 Organs Purchased from Non-Transplant Hospitals - 417 -$ 64

65 Organs Purchased from OPOs 359 21,115 -$ 65

66 Total (sum of lines 62 thru 65) 6,634 31,036 -$ 66

67 Organs Transplanted 6,401 22,414 467,053,241$ 67

68 Organs Sold to Other Hospitals 45 289 658,502$ 68

69 Organs Sold to OPOs 128 6,543 32,592,678$ 69

70 Organs Sold to Transplant Hospitals 22 957 7,465,139$ 70

71 Organs Sold to Military or VA Hospitals - - 1,116,000$ 71

72 Organs Sold Outside the U.S. - - -$ 72

73 Organs Sent Outside the U.S. (no revenue received) - - -$ 73

74 Organs Used for Research - 174 -$ 74

75 Unusable/Discarded Organs 1 663 -$ 75

76 Total (sum of lines 67 thru 75 should equal line 66) 6,597 31,077 -$ 76

(1) Organs procured outside your center by a procurement team from your center are not to be included in the count.(2) Organs procured outside your center by a procurement team are included in the count.

• Total revenue applicable to organs furnished to other providers, to OPOs and others, and for organs transplanted into non-Medicare patients.

• If organs are transplanted into non-Medicare patients who are not liable for payment on a charge basis, and as such there is no revenue applicable to the related organ acquisitions, the amount entered on line 58 must also include an amount representing the acquisition cost of the organs transplanted into such patients.

• Determine this amount by multiplying the average cost of organ acquisition by the number of organs transplanted into non-Medicare patients who are not liable for payment on a charge basis.

Revenue for Organs Sold(from Medicare Provider Reimbursement Manual)

FY09 Reported Organ RevenueHospitals Reporting >=1 Excised Organ

Hospitals That Reported

% Hospitals in Dataset

Excised Organs Reported

221 94% 14,226 Hospitals Reporting Revenue for Organs Transplanted

Hospitals That Reported

% Hospitals in Dataset

Transplanted Organs Reported

% Total Organs Transplanted

Reported by All Hospitals

Total Revenue Reported

Rev Per Organ Transplanted

53 23% 7,089 25% $467M $65,884 Hospitals Reporting Revenue for Organs Sold

Hospitals That Reported

% Hospitals in Dataset

Sold Organs Reported

% Total Organs Sold Reported by

All HospitalsTotal Revenue

Reported Rev Per Organ Sold

114 49% 4,665 58% $42M $8,967

Average FY09 Medicare Settlement by Hospital Transplant Volume

Total Usable Organ Volume

Hospitals % Medicare

Avg Medicare

Settlement Amount

Medicare Cost Per Organ

1-20 26 61% $ 546,985 $ 81,733 21-50 40 64% $ 1,501,100 $ 63,606 51-100 54 70% $ 2,920,823 $ 55,871 101-200 52 62% $ 4,602,623 $ 51,782 201-300 26 54% $ 7,320,823 $ 54,790 301-400 16 52% $ 9,926,582 $ 55,436 401+ 19 54% $14,313,291 $ 45,303 All 234 57% $ 4,718,163 $ 52,564

Common Errors: Decrease Medicare Ratio/Payment

• “Unusable/Discarded Organs” not subtracted from total organs to calculate “Total Usable Organs”

• No Days or Less Days than Excised Organs Reported for "Inpatient Routine" but did report Excised Organs

• Did not report Excised Organs, but had Excised per SRTR Data

Common Errors: Audit Risks for Medicare Overpayment

• No Revenue reported for Organs Sold or Transplanted

• “Usable Organs” and “Medicare Usable Organs” on Lines 54/55 differs from adding organ statistics schedule

Cost Report Costs, Transplant and Donor Volumes by Year

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

-

500.0

1,000.0

1,500.0

2,000.0

2,500.0

-

5,000

10,000

15,000

20,000

25,000

30,000

35,000

Medicare Payments Total Costs Transplants Donors

Tota

l Cos

ts (i

n m

illio

ns)

Tran

spla

nts

and

Don

ors

$1.1billion

Average Cost Per Organ by FY

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

$-

$10,000

$20,000

$30,000

$40,000

$50,000

$60,000

$70,000

Medicare Payment Per Organ Total Cost Per Organ

Average Cost Per Organ by FY

Fiscal Year Medicare

Payment Per Organ

Organ Cost If used 3% annual

inflation

Dialysis Medicare

Payments Per Patient Year

(USRDS)

Total Transplants

(UNOS)

1996 $ 28,635 30,917 52,879 19,765 2010 $ 56,101 46,765 86,608 28,661

Increase 1996 to 2010 96% 51% 64% 45%

Cost Drivers• Increased overhead resulting from regulatory

requirements

• Increased costs of OPOs, HLA (also paid on Cost Reports)

• Education about allowable costs on Cost Report

• The system is not designed to incentivize cost reduction

1-20 21-50 51-100 101-200 201-300 301-400 401+ $-

$10,000

$20,000

$30,000

$40,000

$50,000

$60,000

$70,000

$80,000

FY09 Total Cost Per Usable Organ by Hospital’s Total Volume of Organs

Range of Usable Organs for Hospital in FY2009

Heart Kidney Liver Lung $-

$10,000

$20,000

$30,000

$40,000

$50,000

$60,000

$70,000

$80,000

$90,000

FY09 Total Organ Acquisition Costs Per Usable Organ by Type of Cost

Indirect Costs Salaries & Other Direct CostsRoutine & Ancillary

HR IN KI LI LU PA $-

$10,000

$20,000

$30,000

$40,000

$50,000

$60,000

$70,000

$80,000

$90,000

$100,000

FY09 Organ Acquisition Costs Per Total Usable Organs and Per Transplanted Organs

Direct OAC Per Usable Organ Direct OAC per Transplanted Organ

1 2 3 4 5 6 7 8 9 10 11 $-

$20,000

$40,000

$60,000

$80,000

$100,000

$120,000

Heart: Avg Total Cost Per Organ by UNOS Region

1 2 3 4 5 6 7 8 9 10 11 $-

$10,000 $20,000 $30,000 $40,000 $50,000 $60,000 $70,000 $80,000 $90,000 Lung: Avg Total Cost Per Organ by UNOS Region

1 2 3 4 5 6 7 8 9 10 11 $-

$10,000 $20,000 $30,000 $40,000 $50,000 $60,000 $70,000 $80,000 Kidney: Avg Total Cost Per Organ by UNOS Region

1 2 3 4 5 6 7 8 9 10 11 $-

$10,000 $20,000 $30,000 $40,000 $50,000 $60,000 $70,000 Pancreas: Avg Total Cost Per Organ by UNOS

Region

1 2 3 4 5 6 7 8 9 10 11 $-

$10,000 $20,000 $30,000 $40,000 $50,000 $60,000 $70,000 $80,000 $90,000 Liver: Avg Total Cost Per Organ by UNOS Region

2 3 5 6 8 9 10 $-

$50,000

$100,000

$150,000

$200,000

$250,000

$300,000 Intestine: Avg Total Cost Per Organ by UNOS Region

Conclusions• OIG audits are instructive for both risk areas and

potential cost recoveries

• Organ Acquisition cost reporting varies greatly across transplant programs

• Accurate reporting is critical for obtaining maximum reimbursement from both Medicare and non-Medicare payers

• Organ Acquisition costs have increased more than other similar healthcare costs

Resources• CMS – National Cost Report Dataset

http://www.cms.hhs.gov/CostReports/• Milliman & Robertson U.S. Organ and Tissue

Transplant Cost Estimateshttp://www.milliman.com/pubs/HRR20.pdf

• HHS Office of the Inspector General - Audit Reportshttp://oig.hhs.gov/oas/oas/cms.html

• United States Renal Data System Annual Reportshttp://www.usrds.org